ENVI Committee Report

11.    ALTERNATIVES TO PESTICIDES

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11.1    Integrated pest management combines the use of pest control methods (including pesticides) and alternatives to pesticides. Alternative pest management methods may be biological controls, but are not necessarily so. Plants which have been genetically modified to resist pests are one type of alternative pest management tool. Organic agriculture completely proscribes the use of chemical pesticides and genetically modified organisms, relying instead solely on natural or biological fertilizers. Witnesses described the current status of integrated pest management and organic agriculture in Canada, and in particular research and existing strategies in the field. They also questioned the current system of GST exemptions in the agricultural industry as well as the food grading system, and they suggested the possibility of introducing incentives for organic agriculture.

Integrated Pest Management

11.2    Integrated pest management consists of finding and using biological, chemical and other methods to reduce pest populations so that they cause less economic, sociological and ecological damage and so that agricultural systems are less wholly dependent on pesticides.¹⁸⁷ The idea is to combine the use of various compatible control measures such as:

• useful insects such as parasites and predators (biological management);
• bacteria, viruses and fungi (pathogens);
• insect- and disease-resistant plant varieties (including transgenic plants);
• synthetic hormones which inhibit the normal growth process;
• agricultural practices such as crop rotation and mixed farming; and
• behaviour-modifying chemicals and chemical ecology products (in particular pheromones, kairomones and allomones).

11.3    The Urban Pest Management Council explained to the Committee that integrated pest management calls for an assessment of all possible control options. The selection of a pest control method should be based on economic considerations and factors pertaining to effectiveness, public or worker health and safety, and on potential risks to property and the environment.¹⁸⁸ Integrated pest management measures are constantly improving in response to research conducted by specialized businesses in the field.¹⁸⁹

11.4    According to Dr. Jeremy McNeil of Laval University, integrated pest management is preferable to organic agriculture because it is impossible to completely eliminate the use of synthetic insecticides in the short term. Pesticides are a cost-effective solution to certain specific problems of pest infestation. Concerted efforts by farmers, agri-businesses, researchers and the general public could help, however, to considerably reduce the overall use of insecticides in agri-ecosystems.

Integrated Pest Management Research and Strategies

11.5    The Committee was informed about a number of integrated management research projects by federal departments. For example, Natural Resources Canada is conducting research on integrated forest pest management¹⁹⁰ and Agriculture and Agri-Food Canada (AAFC) is working on ways to reduce pesticide use in agriculture.¹⁹¹ The Lethbridge Research Centre (AAFC) has a research program on integrated weed management on the Canadian prairies. The purpose of this program is to develop integrated pest management methods for grains, oilseeds and grain legumes grown in that region. Economic thresholds must be established to enable producers to determine when pest management is justified. Economic thresholds are ascertained with the aid of cost/benefit data on crop rotation, higher planting densities, local fertilizer spreading to help crops compete more effectively with weeds, the use of ground-covering plants, green fertilizers and ensiling for weed management.¹⁹² Agriculture and Agri-Food Canada also allocates a portion of its budget for conversion to organic agriculture and education.

11.6    The Pest Management Regulatory Agency (PMRA) encourages integrated pest management practices by facilitating access to those practices and coordinating integrated pest management (IPM) strategies in various sectors.¹⁹³ Together with the US Environmental Protection Agency, the PMRA has conducted a series of reviews of lower-risk pesticides and biopesticides.¹⁹⁴ There are two benefits for registrants: faster review of applications (one year instead of 18 months) and simultaneous registration decisions in both countries. In addition, costs are not recovered in order to encourage more interest in registration for biopesticides.¹⁹⁵

11.7    The PMRA also coordinates the development of voluntary IPM strategies across the country in cooperation with various partners including: agricultural groups, manufacturers, federal departments, provinces, research institutions and non-governmental organizations. For the 1998-1999 fiscal year, the Agency's sustainable pest management budget was $865,000.¹⁹⁶ With this budget, the Alternative Strategies and Regulatory Affairs Division aims to develop and implement programs and policies integrating sustainable management in the Agency's decision-making process through risk reduction, integrated management, support for the use of biopesticides and low-risk chemical products. Although many other projects mentioned contribute to risk reduction and are part of a comprehensive policy (reviews of low-risk chemical pesticide, biopesticides, organophosphorus replacement products, integrated management strategies and so on), the Agency has no formal risk reduction policy.¹⁹⁷

11.8    A number of organizations such as the Canadian Environmental Law Association (CELA), the Campaign for Pesticide Reduction, the Canadian Public Health Association and the Canadian Association of Physicians for the Environment, maintain that funding for the sustainable pest management program is insufficient to comply with all the commitments of the program and must be revised upwards. Similarly, the Canadian Association of Physicians for the Environment and the Canadian Environmental Law Association emphasized to the Committee that these future resources should be accompanied by a clearly defined PMRA action plan. The Agency should therefore draft a policy with the primary objective of reducing pesticide use. This objective should be in all its activities and decisions be related to this policy. The Agency should reassess its integrated pest management program to ensure that reduced pesticide use and the development of biological methods are fixed as priorities.¹⁹⁸ The registration process should also reflect the policy's objective. For example, the existence of a lower-risk alternative to a pesticide could result in a refusal to approve a product. This objective should also serve as a guide to the use of approved pesticides. According to Mr. Paul Muldoon, Executive Director of CELA,

11.9    The Committee believes that these are very relevant suggestions that would enable the PMRA to carry out its mandate more effectively and thus further protect the environment and health of Canadians.

11.10    The Committee was informed that farmers are helping to reduce pesticide use and promote integrated pest management. According to the Canadian Federation of Agriculture (CFA), Canadian farmers are leading the way when it comes to sustainable practices by using, for example, methods designed to protect the soil.²⁰⁰ These methods afford environmental benefits (reduced fuel consumption, soil erosion and compaction, increased crop yield and organic matter in soil). Increasing numbers of farmers and specialized producer groups are taking part in integrated pest management programs using, for example, combined biological, crop, physical and chemical methods to optimize integrated management benefits and minimize health and environmental risks. Farmers favour these sustainable agricultural practices because they are aware of the effects that pesticides have on their own health and that of their families. According to the CFA, Canadian farmers currently use only the minimum quantities of pesticides necessary for agricultural production purposes and this situation is partly due to the fact that integrated pest management has become standard practice. The Federation added that the quantities of pesticides used per square kilometre of cultivated land are comparable to those employed in Europe and the United States.

11.11    The Crop Protection Institute emphasized that farmers have nothing to gain by using more than the required quantity of pesticides as they seek to reduce their production costs and preserve the environment for future generations. The Institute believes that more recent products are less harmful to the environment (less toxic for human beings, more specific, more biodegradable, decreased necessary quantities).²⁰¹

11.12    The Canadian Federation of Agriculture (CFA) noted that it appreciates the strict Canadian regulatory system, but criticized the fact that the registration process is too slow, delaying the registration of new products which, in the Federation's view, are more ecologically sound. The Prince Edward Island Ministry of Technology and the Environment agreed on this point, emphasizing that the approval of low-risk pesticides is a priority.²⁰² (See Chapter 15, "Institutional Changes," regarding the recommendation on the PMRA's priorities, particularly the development of pest control products that are safer for the environment and human health.)

11.13    Nature-Action Québec is implementing projects that prove biological pest control methods have a promising future, provided the environment's natural biodiversity is respected and the necessary energy is expended to develop the public's perception of those methods. The organization, which for a number of years has been increasing public awareness of the benefits of environmentally safe lawns (Appendix 11.1), convinced Committee members that these types of approaches are feasible in both horticultural and urban environments. Alternative methods help to protect rather than degrade the environment, a fact that should be considered by those who determine the profitability of ecological methods relative to traditional methods. The Committee supports organizations such as Nature-Action Québec, Action Chelsea for the Respect of the Environment, Citizens for Alternatives to Pesticides and the Canadian Association of Physicians for the Environment in their bid for financial resources for research and dissemination of information to Canadians respecting alternative methods. By information, we mean both providing information to professional pesticide users and increasing the awareness of the general public with regard to alternatives.

Examples of Biological Management The methods with a high potential for success in managing the apple curculio are: planting orchards so as to reduce sources of curculio infestation; mechanically striking branches to dislodge curculios; the use of insect pathogenic fungi. The methods for apple fruitworm control include the use of viruses and mating confusion. By encouraging natural enemies and through the use of insect pathogenic fungi, biological management should be the favoured method for managing the tern stink bug. Apple maggot populations can effectively be reduced by placing baited red spheres in orchards and regularly gathering apples that have fallen to the ground. The best strategy for the red spider and temperate red spider mite is to eliminate or limit the use of broad-spectrum insecticides so as to promote the action of natural enemies. Lastly, the methods with a high potential for success against the scab are the use of resistant varieties, mineral fungicides and scab enemies. (Update on main alternative apple growing methods in Quebec, research conducted for the ministère de l'Agriculture, des Pêcheries et de l'Alimentation du Québec (MAPAQ) by Nature-Action Québec, November 1999.)

11.14    Like a number of witnesses (including the Working Group on the Health Dangers of the Urban Use of Pesticides, the Campaign for Pesticide Reduction and the Canadian Public Health Association), the Committee believes that increase availability of alternatives to pesticides will reduce the public's risk of exposure to these products and promote a reduction in their use. Consequently, additional funds should be allocated to developing alternatives and making them available to the public. Alternatives such as integrated pest management are worth promoting. The Canadian Public Health Association believes that alternatives to pesticides are, among other things, realistic ways of reducing the adverse health effects of these products. Although integrated management does not completely eliminate the use of pesticides, it does make it possible to put a stop to the use of certain particularly toxic products.

11.15    Similarly, the Committee believes it is possible to promote alternatives to pesticides by changing the name of the existing Pest Control Products Act with the new Pest Control Act. The Canadian Environmental Defence Fund and the Commissioner of Environment and Sustainable Development recommended that action be taken to correct the federal government's inability to promote the development of alternatives to pesticide use. The principle of pesticide substitution should therefore be included in the new Pest Control Act, as is done in Sweden. In 1990 the Swedish legislation on chemical products was amended to include a definition of the substitution principle which reads, "Anyone handling or importing a chemical product must take such steps and otherwise observe such precautions as are needed to prevent or minimize harm to man or the environment. This includes avoiding chemical products for which less hazardous substitutes are available." According to this definition, if a new pesticide is registered that is safer than an older one, the older one automatically loses its registration.²⁰³ Failure to apply the substitution principle is a violation of law in Sweden. Subsequently, the Swedish Parliament passed an Environmental Code which came into force on January 1, 1999. Fifteen pieces of legislation were amalgamated in the Environmental Code, including the legislation on chemical products act.²⁰⁴ The substitution principle is now called the "product choice principle" and is defined as follows:

11.16    In the Environmental Code, a chemical product includes a product that has been specially produced to act as a pesticide, or for some other technological purpose, or which completely or partially consists of living micro-organisms, nematodes, insects or spiders. The Code also states that the product choice principle applies not only to commercial sale and use, but also to individuals. The Committee is of the opinion that Canada should put Sweden's experience with pesticide management to good use. Specifically, the PMRA should withdraw the registration of a pesticide when a less toxic product or procedure, or a non-chemical process, becomes available.

Organic Agriculture

11.17    Organic agriculture proscribes the use of chemical pesticides and relies instead on natural and organic fertilizers. Organic agricultural practices are designed to re-establish and preserve ecological stability in the environment. For this purpose, soil fertility systems must maintain maximum biological activity in the soil and conserve natural resources. Pest management is carried out using biological, cultural and mechanical methods including mechanical tillage, crop rotation, residue recycling, water management, increasing beneficial insect populations, and the promotion of biodiversity. The primary goal of organic agriculture is to promote and develop sustainable environmentally friendly farming.²⁰⁶ According to Dr. Peter Stonehouse of Guelph University, there are a number of reasons to take an interest in organic agricultural methods. Dr. Stonehouse has written a number of articles on the economic and environmental benefits of organic agricultural businesses. Organic agriculture, he says, was developed in order to solve the problems caused by conventional agriculture. The problems he refers to include soil erosion and degradation, non-point source pollution and deteriorating wetlands.²⁰⁷ Organic farming causes less damage to the environment for at least three reasons:

• not using pesticides and synthetic fertilizers eliminates the potential for damage to the environment from those sources;
• the absence of synthetic fertilizers forces farmers to observe the soil conservation ethic of maintaining and recycling soil nutrients on their lands, thus reducing the risk of pollution in the area surrounding their farms; and
• emphasis is placed on soil recovery in winter through the use of forage crop plants, winter grains and ground-cover plants, which improves soil condition and reduces the risk of erosion, degradation and compaction.

Apart from protection of the environment, biodiversity and ecological equilibrium, organic agriculture is designed to respond to concerns about food quality, human health and animal welfare. It is also intended to protect natural resources and maintain the ecological viability of agriculture.²⁰⁸

The Situation in Other Countries At present, although organic farming is still a marginal sector, it occupies nearly 2% of all EU farmland and over 1% of farms; percentages vary a great deal from one country to another (12% of farms in Sweden; 9% in Austria; 4% in Finland). Denmark is a good example of a European country that has adopted a policy on organic farming. In February 1999, Denmark's Minister of Health, Agriculture and Fisheries announced an action plan that would continue to support Denmark's organic farming sector into the 21st century, and proposed US$ 338 million in funding for both production and marketing for the five-year period from 1999 through 2003. The action plan calls for 10% of Danish farmers to use organic methods by the year 2003, tripling Denmark's current organic production. In 1998 in Denmark, approximately 2,500 farms used or were converting to organic methods -- double the number doing so in 1996 -- and some 99,000 hectares or 3.7% of farm acreages were being farmed organically. With the addition of these converted farms and acreages, it is expected that in 1999 these figures will increase to 3,300 farms and 150,000 hectares. Denmark's main organic products are meat, eggs, vegetables, grain, and dairy products: approximately 20% of milk produced in Denmark is organic. The average acreage of an organic farm in Denmark is 38.5 hectares, which is comparable to the size of a traditional Danish farm. (Eurostat news release; see also complete report "Agriculture, Environment, Sustainable Development Facts and Figures: A Challenge for Agriculture, 1999," US Department of Agriculture, Foreign Agricultural Service (FAS) Online, March 1999.)

11.18    Organic farming is a niche market in Canada which has been growing at an annual rate of 20% in recent years.²⁰⁹ According to the Canadian Organic Advisory Board, Canadian organic production totals nearly $1 billion per year. This trend is all the more surprising since, prior to June 1999, there was no national organic production standard. The organic products market in Canada is dominated by imports from the United States and Europe (80%). The Canadian Organic Advisory Board (COAB) estimates that 85% of Canadian organic production is exported and that demand for certain products, in particular grains and oilseeds, is exploding.

Canadian National Organic Agriculture Standard

11.19    The Canadian National Organic Agriculture Standard was announced by the Government of Canada on June 29, 1999. The standard defines the term "organic" and is designed to reinforce production as well as the principles and practices of ecological management that apply to organic farming. The standard places emphasis on recycling and promotion of biodiversity and also covers the period of conversion to organic farming, production plans and files, plant and animal production, production requirements for maple products, honey, greenhouse crops, mushrooms, sprouts, wild and natural products as well as production and processing, packaging, labelling, storage and distribution of organic products. This new standard was drafted with the Canadian General Standards Board (CGSB) and is voluntary. At present, there is no federal policy aimed specifically at the organic industry. However, the Committee believes that federal government involvement beyond the adoption of a voluntary standard is necessary.

Goods and Services Tax

11.20    In their presentation to the Committee on December 13, 1999, the authors of the book "Real Food for a Change" claimed that the input tax exemption enjoyed by farmers would encourage them to use pesticides:

11.21    However, the Committee was subsequently informed that virtually all agricultural inputs (tools, machinery, crop seed, etc.) are tax exempt, not only pesticides. Consequently, all farmers enjoy a tax exemption on inputs, whether they engage in conventional or organic agriculture, grow field crops or raise livestock, manage small or large agri-businesses.²¹¹ Furthermore, the exemption from the GST on all inputs is not a 7¢-on-the-dollar benefit for farmers in using pesticides. Farmers do not pay the GST on their inputs and do not have to bill it when they sell their products. When the GST was introduced, the federal government decided that food would be tax exempt and that food producers such as farmers should therefore also benefit from this tax measure. Changing this tax measure respecting agricultural inputs would mean restarting the debate over whether the GST should be charged on food products. No witness made this suggestion.

Tax Incentives for Organic Agriculture

Conversion to Organic Agriculture in Europe From 1991 to 1996, the number of organic farms in Austria increased from 1,500 to 23,000 and the area in organic production from 17,000 to 225,000 hectares. The EU's objective for the year 2000 is 2.5%; Austria's objective is 20%. The last decade has witnessed a mini-boom in organic farms as a result of European incentives. The number of certified farms in Western Europe increased from 10,000 to more than 50,000 between 1987 and 1997. The area of land under organic cultivation has increased eight times. Half of this land is being converted to organic agriculture with the aid of the National and European Funds. (Tamara Thiessen, "It's not easy being green, EU Finds", The Gazette, Montreal, Tuesday, February 15, 2000)

11.22    According to the Canadian Organic Advisory Board, sustainable pest management strategies can be promoted in various ways. Some European countries offer tax incentives to farmers to encourage them to eliminate pesticides and synthetic fertilizers with the aid of programs that have been integrated into agricultural and environmental policies.²¹² For example, entire valleys in Austria have been converted to organic agriculture as a result of European Union funding. Between 1991 and 1996, the number of Austrian organic farms increased to the point where they now represent half of all organic farms in Western Europe (see text box).

11.23    The increase in the amount of farm land converted to organic agriculture has been observed in Europe is a result of this type of incentive, together with an increase in the volume of certified organic products destined for foreign markets. Committee members are concerned by the fact that Canada's organic agricultural sector enjoys no subsidized promotion programs. Such tax incentives would encourage the transition to organic agriculture, particularly if they were part of a federal policy.

Food Grading System

11.24    Some Committee members also expressed concern at witnesses' assertions that the present food grading system encourages farmers to use pesticides:

11.25    Witnesses explained, for example, that apple growers may make as many as 16 applications of pesticides per year to combat apple scab although this fungus, in small quantities, has little effect on the fruit's nutritional value. Producers, they said, are tempted to use more pesticides because one harvest may be graded lower if it shows minor (visual) damage and thus bring a lower price.²¹⁴ One witness, therefore, recommended that the present grading system be changed so that it is no longer based on visual aspects, but rather the nutritional value of the consumer product and thus, indirectly, on reduced pesticide use.

11.26    On the one hand, the witness suggested that pesticide-free foods have a less attractive appearance, which is not necessarily true. On the other hand, the grading system which is applied to both organic and conventional products, meets international requirements. If Canada were to deviate from it, the entire international system for harmonizing and comparing standards would have to be reviewed. Although the grading system is part of a national policy, it serves above all to facilitate trade between Canada and its trading partners. Changing the grading system as proposed would mean changing the ground rules of international trade.

11.27    Labelling would thus appear to be the way to provide consumers with nutritional information on products and other types of information such as the use or non-use of pesticides. Certain types of labelling already tell consumers whether a product has been organically produced. Once the recently adopted "Canada Organic" standard can be granted by a nationally recognized certification organization, Canadian and foreign consumers will have additional assurances as to the organic nature of products.

11.28    Since consumers have more contact with the labelling system than the grading system, it seems logical to improve Canada's labelling system so that it can inform consumers adequately. In this way, consumers may choose foods on the basis of their nutritional value and organic nature rather than their appearance.

Organic Agriculture Research

11.29    A number of organic agriculture research projects are being carried out within the federal government. For example, a team from the Lethbridge Research Centre is developing techniques to produce crops that do not require pesticide use.²¹⁵ Government research in the field, however, does not appear to be a priority in Canada. The situation scarcely seems any better in the universities, where students do not have access to appropriate courses in organic agriculture. The following comments by witnesses Dr. Stonehouse and Dr. McNeil, respectively, reflect the concerns of a number of experts who addressed the topics of research and education as a whole:

11.30    The Canadian Organic Advisory Board had a similar view. In the Board's view, it may be seen from a comparison between the Canadian and European situations that there is little data on many aspects of organic production in Canada and regional specialists are scarce.²¹⁸ In view of these obvious deficiencies in training and availability of scientific expertise, the Committee is convinced of the importance of helping and supporting the organic agriculture field.

11.31    In the Throne Speech in October 1999, the Governor General announced the creation of 2 000 research chairs as part of the 21st Century Chairs for Research Excellence Program.²¹⁹ This announcement was confirmed by the Minister of Finance when he tabled his budget on February 28, 2000:

11.32    The Committee applauds this initiative, which will help consolidate innovation systems across Canada, and sees this as an outstanding opportunity for the government to promote research in organic agriculture.

11.33    Organic agriculture is a vast sector, as may be seen from the number of topics addressed as part of the study on pesticides. A number of other themes could be developed in greater depth including the economic and environmental aspects of organic agriculture, biological pest management techniques, the study of the "Canada Organic" standard and development of future organic agriculture legislation. These subjects deserve further attention as part of future research efforts.

 

Appendix 11.1: The Environmentally Safe Lawn

Based on Nature-Action Québec's expertise, a beautiful lawn can be achieved without chemicals using the following tips:

• Ensure soil is well prepared. Good arable land is essential in order for grass to become deeply rooted and flourish for many years. The soil must be well turned to 15 or 20 cm in depth, with the organic matter and minerals essential to good growth added. Unfortunately, most lawns are installed hastily on compacted earth from excavation.
• Plant the right species in the right place. Lawns are made up of plants that require sun and a great deal of water. In shady areas, it is better to plant species that tolerate shade. However, certain species are also more resistant to dry conditions and treading. If conditions are too harsh for grass, ground covers or other treatments should be considered.
• Ensure adequate maintenance. Regular or seasonal care will keep lawns dense and in good condition. This includes fertilization, cutting, watering, aeration and so on. These are all minor tasks that must be performed adequately and at the right time to ensure a vigorously growing lawn. Most people cut their lawns too short, resulting in lawns that are more sensitive to dry conditions and parasites.
• Accept diversity as an integral part of a healthy environment. A lawn is not an artificial carpet. It is a living area which contains a host of inoffensive and even highly useful organisms (plants, insects and earthworms).
• Understand that infestations are merely symptoms of an underlying problem. It is not a good idea to apply pesticides (even organic ones) repeatedly in order to solve this kind of problem. It is better to correct it at the source, even if that means replacing the lawn with something more suited to the environment. The best weapon against infestation is prevention and maintenance of a diversified environment in which competition among organisms prevents domination by any single one.

Source: Nature-Action Québec, Brief to the Committee

 

Appendix 11.2: Alternative Ecological Solutions

Pest control on the farm	Pest control in the home garden
Companion planting entails the growing of two species of plants together, one chosen because it repels pests that would attack the other.	Companion planting works very well in home gardens. Many insects avoid garlic, chives, mint, anise, coriander, geraniums, nasturtiums and many other plants. For example, plant one of these species near your rosebushes and it will keep aphids off.
Crop rotation (planting different crops on the same land at different times) can eliminate a pest by removing its host for at least one growing season.	Crop rotation also works well in a home garden. Pests that infest potatoes, for example, may not survive a season in which onions are grown in the potato patch instead.
Sex attractants can be used to frustrate and confuse breeding adults in the quest for mates. Food attractants can be used to lure and trap pests.	Some gardeners enlist the help of wildlife and domestic animals. Domestic ducks, for example, relish most of the weeds that grow in strawberry and cabbage patches. Fennel attracts tiny wasps that both fertilize flowers and are parasites to many insect pests. Bird houses and flowering shrubs help attract some insect-eating birds to the home garden.
Selective breeding encourages plants that resist particular pests -- rust-resistant wheat, for example.	Some natural substances can be used as traps. A brew of molasses and lemon juice in water, for example, will attract and drown earwigs. Slugs react the same way to beer or honey. A mixture of peanut butter and boric acid will attract and kill carpenter ants.
Natural predators can be introduced to compete with harmful insects.	Many natural "teas" are effective pesticides and insect repellents. These include brews made from rhubarb, onion, garlic and soap. They can be spread on the ground, brushed on tree trunks or sprayed directly on plants.
Mechanical or manual weeding and tilling are simple age-old methods that also have the advantage of reducing soil erosion and compacting, and increasing yield and the quantity of organic matter in the soil.

Sources: Agriculture and Agri-Food Canada, Web site, Environmental Sustainability of Canadian Agriculture: Report on the Agri-Environmental Indicators Project, March 2000; Environment Canada Web site, April 2000

 

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¹⁸⁷ J. McNeil, Supplementary information provided to the Committee.

¹⁸⁸ Urban Pest Management Council, Brief to the Committee.

¹⁸⁹ Crop Protection Institute, Brief to the Committee.

¹⁹⁰ Evidence, Meeting No. 127, June 2, 1999.

¹⁹¹ Evidence, Meeting No. 128, June 8, 1999.

¹⁹² Lethbridge Research Centre, Agriculture and Agri-Food Canada, Brief to the Committee.

¹⁹³ Pest Management Regulatory Agency, Web site, December 1999.

¹⁹⁴ Evidence, Meeting No. 126, June 1, 1999.

¹⁹⁵ Pest Management Regulatory Agency, Web site, December 1999; C.A. Franklin, supplementary letter to the Committee, February 17, 2000.

¹⁹⁶ C.A. Franklin, correspondence to the Committee, August 24, 2000.

¹⁹⁷ C.A. Franklin, correspondence to the Committee, February 14, 2000.

¹⁹⁸ P. Stonehouse, Ph.D., University of Guelph, letter sent to Geraldine Graham, PMAC Secretariat, Health Canada, February 19, 1999; J. H. Borden, Professor, Simon Fraser University, correspondence to Dr. R. J. Van Loon, Chair, Advisory Council, Pest Management Advisory Council, February 24, 1999.

¹⁹⁹ Evidence, Meeting No. 11, December 1, 1999.

²⁰⁰ Canadian Federation of Agriculture, Brief to the Committee.

²⁰¹ Crop Protection Institute, Brief to the Committee.

²⁰² Prince Edward Island Ministry of Technology and Environment, Brief to the Committee.

²⁰³ Excerpt from Rachel's Environment & Health Weekly, No. 670, September 30, 1999.

²⁰⁴ Extract from the Environmental Code of Sweden, documentation from the Swedish Embassy, March 2000.

²⁰⁵ Personal communication, The Environmental Code of Sweden, extract, March 2000.

²⁰⁶ Canadian General Standards Board, Organic Agriculture, National Standard of Canada, Standards Council of Canada, CAN/CGSB-332.310-99, 19 p. + appendices.

²⁰⁷ Y.O. Sheba, P. Stonehouse and E.A. Clark, "Environmental and Economic Benefits of Organic Dairy Farming in Ontario," Environmental Management, p. 151-156; R.S. McDonald, Executive Director, Canadian Organic Advisory Board, Brief to the Committee.

²⁰⁸ Evidence, Meeting No. 13, December 7, 1999.

²⁰⁹ U.S. Department of Agriculture, FAS Online, Web site, March 1999.

²¹⁰ W. Roberts, R. MacRae and L. Stahlbrand, Brief to the Committee.

²¹¹ J.D. Fréchette, Pesticides and the GST, Parliamentary Research Branch, Library of Parliament, February 3, 2000.

²¹² R. McDonald, Canadian Organic Advisory Board, Brief to the Committee.

²¹³ W. Roberts, R. MacRae, L. Stahlbrand, Brief to the Committee.

²¹⁴ R. MacRae, correspondence to the Committee, February 2000.

²¹⁵ R.E. Blackshaw, Agriculture and Agri-Food Canada, Lethbridge Research Centre, Alberta, Brief to the Committee.

²¹⁶ Evidence, Meeting No. 13, December 17, 1999.

²¹⁷ Ibid.

²¹⁸ R.S. McDonald, Executive Director, Canadian Organic Advisory Board, Brief to the Committee, correspondence from the Board to the House of Commons Agriculture Committee, June 3, 1999.

²¹⁹ Association of Universities and Colleges of Canada, New Research Chairs Important and Innovative Building Blocks, Press Release, October 13, 1999.

²²⁰ Minister of Finance, the Honourable Paul Martin, P.C., M.P., Hansard, February 28, 2000.